Restart
Failed Restart After a Shutdown: What Owners Should Do
Under OSHA 29 CFR 1910.119(m), an incident that caused or could reasonably have caused a catastrophic release must be investigated, starting as promptly as possible and no later than 48 hours after it. A team including someone who knows the process writes a report with contributing factors and recommendations, resolves each finding, shares it with affected staff, and keeps it five years. Review changes through management of change and the pre-startup review before trying again.
How MaintWiz helps: The MaintWiz shutdown module carries this work as work packages with checklists, readings and photos, permits and readiness gates, so the result stays with the work order.
By Jai Balachandran · Technical review: Murali Nerur Pasupathy · Published · Last reviewed
What MaintWiz adds:Critical path and floatReadiness gatesPermits and isolationsChecklists with readings
OSHA duties
What does OSHA PSM require after a failed restart?
The 48 hours is the latest time to begin the investigation, not the time to finish the report.
| Duty | What it requires (paraphrased) | Timing | Paragraph |
|---|---|---|---|
| Incident investigation | Investigate incidents that caused or could reasonably have caused a catastrophic release | Start no later than 48 hours after the incident | 1910.119(m)(1)-(2) |
| Investigation team | At least one person who knows the process, a contractor employee if relevant, others with expertise | With the investigation | 1910.119(m)(3) |
| Report and follow-up | Record the dates, description, contributing factors and recommendations; resolve and document actions; review with affected staff | Resolve promptly; keep the report 5 years | 1910.119(m)(4)-(7) |
| Management of change | Written MOC for changes other than replacement in kind; train affected people before restart | Before the change and before restart | 1910.119(l) |
| Pre-startup safety review | Confirm equipment, procedures and training before hazardous chemicals are introduced after a significant modification | Before chemicals are re-introduced | 1910.119(i) |
Actions
What should the owner do in the first days?
Protect the evidence, start the investigation and do not restart on the same assumptions.
- Make the unit safe and keep the evidence: logs, trends, procedures, permits and phone instructions.
- Start the investigation within 48 hours with a team that includes someone who knows the process and, if contractors worked on it, a contractor employee.
- Record the contributing factors, not only the immediate cause, and write the recommendations.
- Treat repair changes as changes: run management of change and update procedures and training before restart.
- Run the pre-startup review again where the repair is a significant modification.
- Learn from public cases: after BP Texas City (2005), the US Chemical Safety Board found abnormal start-ups had not been investigated and a key instruction was given by phone and not logged.
- UK HSE guidance notes that many hazards arise at start-up or shut-down and these phases need specific procedures kept current through controlled change.
FAQ
Frequently asked questions
Must an aborted start-up be investigated under OSHA PSM?
If it caused or could reasonably have caused a catastrophic release of a highly hazardous chemical, yes, and the investigation must start within 48 hours.
Does the 48 hours mean the report is due in 48 hours?
No. The 48 hours is the latest time to begin the investigation. The rule sets no deadline for finishing the report.
How long are investigation reports kept?
Five years under 1910.119(m).
When does a repair after a failed start-up need MOC and a pre-startup review?
MOC applies to changes other than replacement in kind; a pre-startup review applies to modifications significant enough to require updated process safety information. Both are completed before the process is restarted.
Sources
Sources
OSHA rule text, CSB and UK HSE material, read on 30 October 2026. UK reporting duties are not covered here.
Plan this work in the shutdown module
Book a demo and bring your next shutdown scope. We will show how the work, the permits and the results sit in one plan.